RAC has adopted its opinion on ECHA’s proposal to restrict the use of microplastics that are intentionally added to products on the EU/EEA market, in concentrations of more than 0.1 % weight by weight.
Nanoscale materials included within restrictions: RAC opposes the intial ECHA proposal that a lower size limit of 100nm should be imposed (proposed as detection methods are still under development) with the position that a size limit is not necessary as the restriction can be enforced in other ways, such as supply chain management.
Other key parts of the opinion included:
Biodegradable polymers: ECHA’s proposal set out specific test methods and pass criteria for identifying biodegradable polymers, which are excluded from the restriction. RAC wanted to see greater evidence that microplastics are biodegradable in the environment (e.g. soils, marine environment, freshwater).
Use of microplastics as infill material on artificial turf pitches: RAC recommended a complete ban after a transition period of six years as there was incomplete information on the effectiveness of risk management measures. A ban would also be more effective than risk management measures in preventing environmental releases in the long term.
ECHA’s Committee for Socio-economic Analysis (SEAC) agreed on its draft opinion on the costs and benefits of this proposal for society. SEAC supports the wide scope of the proposal and the transition periods for different product groups to give companies time to prepare. Although the benefits cannot be assessed in monetary terms, the cost-effectiveness of the proposal can be estimated. It noted that microplastic pollution is irreversible and that early action to reduce emissions can be beneficial for society. For practical reasons and to ease enforcement, SEAC recommends a lower size limit of 100 nanometres until suitable analytical methods are available.
A 60-day consultation of SEAC’s draft opinion will start soon. The consolidated opinion of both committees is expected to be ready by the end of 2020. The decisions on REACH restrictions are taken in the European Commission by the EU Member States and scrutinised by the Council and the European Parliament.
